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By way of an amendment to the Foreign Exchange Management (Transfer or Issue of Security by a Person resident outside India) Regulations, 2000 (“Amendment”), the RBI has placed a new disclosure requirement upon Limited Liability Partnerships (“LLPs”) that have received FDI by issuing a notification on September 30, 2015 (“Notification”). The Notification sets forth that all LLPs that have received FDI in the previous year(s) or the current year shall submit to the RBI, on or before the 15th of July of each year, a report titled as ‘Annual Return on Foreign Liabilities and Assets’ (“FLA Return”), as specified by the RBI from time to time. The FLA Return was earlier required to be submitted by all Indian companies that received FDI, or made FDI abroad, but has now been made applicable to LLPs as well.

While the Form FC-GPR exists for the reporting of FDI details, the RBI in 2011 replaced Part B of the above form with the FLA Return, for a more comprehensive reporting of FDI. LLPs are increasingly partaking in FDI, and the Amendment ensures specific disclosures for a more comprehensive reporting of FDI activity in the country.

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